Your Petitioner Ben represents that he is now held in slavery in St. LouisSt Louis by ThomasThomas I WhiteWhite for the who claims your petitioner us his slave. Your petitioner States that in the fall & winter of eighteen hundred & thirty threesaid said L there claiming your - Petitioner as his slave caused your Petitioner to be hired to Labor at Scuagirts baalBanks in the State of IllinoisIllinois where he was kept at Labor with the knowledge and consentof said far the space of sworn by Reason where of your petitioner says he is entitled to his freedom your-. Petitioner therefore prays that he may be permitted to sue as a poor person to establish his freedom that counsel may be assigned to him & that such may be made for his personal Security as the Law warrants& he will pray

I Luke ELuke E LawlessLawlessLuke E Lawless Judge of the Third Judicial Terminal of the State ofMissouriMissouriMissouri do hereby order that the withinnamed petitioner Ben be allowed to sue as a poor person to establish his freedom and assign to him as his counsel to commanded & prosecute his Said

and I do further order that said Ben have reasonable liberty ato attend his counsel & the Court as occasion may require; and that he be not removed out of the Juridiction of the Court, and that he the not subject to any security because of his application for freedom.

St Louis County Ben a man of color complains of ThomasThomas I & the claim & of plea of trespassfalse imprisonment do far that here to on the first day of December in the year of eighteen hundred & thirty fivethe said defendants with forced arms on a peace do make upon him said Ben & him said Ben did then & there imprison any just or probable cause whatever& have unlawfully kept & detained him in prison there from them untill the commencementof this said and the plaintiff that at & the commetting of the said secural grievances he & still is a free person & the defendant had & detained & still detains him in slavery where he says he is greatly & hath sustained Damage to one hundred Dallors therefore he said

I Luke E.Lawless Judge of the third Judicial Circuit of the State of missouri do herebycertify order that the within named petitioner Ben be allowed to sue as a poor person to establish his freedom and assign to him GustavusGustavus A BirdA BirdGustavus A Bird as his Counsel to commence & presecute his suit. and I do furthr order that said Ben have reasonable liberty to attend his counsel & the court as occasion may require and that he be not removed out of the Jurisdiction of the court and that he be not subject to any

We command you to summon ThomasThomas Of WhiteWhite andWilliams L Woods. that they be and appear before the Judge of our CircuitCircuit CourtCourtCircuit Court at the next term thereof to be held at the city of St.LouisSt Louis within and for the County of Saint LouisCounty of Saint Louisforthe second monday of march next then and there to answer unto Ben a man of colour of a plea trespassfalse imprisonment to the damage of the said plaintiff of one Hundred Dollars and have you then there this writ.

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Witness John RulandJohn Ruland Clerk of our said Circuit CourtCircuit Court at office this nineteenth day of January AD 1836

Executed this writ by reading it together with the decleration and order of the honb. Judge to WhiteWhite on the 20th day of January 1836 in the county of St. LouisSt Louis L. Woods not found in my county

Suit for freedom In St. Louis Circuit CourtCircuit Courtmarch Term 1836

AndtheJ.said & Woods

And the said ThomasThomasby HudsonHudson his attomy and defends the force when and saith that he is gently of the said supposed trespass and false imprisonmentabove said to his or any thereof in manner and form as the said BenjaminBenjamin above thereof complained against him and of this he the said ThomasThomas himself upon the

Depositions of witnesses produced Sworn and examined on the thirteenth day of October in the year of our Lord eighteen hundred and thirty eightat the office of Patrick WalshPatrick Walsh in the City of St. LouisCity of St Louisand state of MissouriMissouri and by consent of the attorniesJames BJames B Bowlin and AlexanderAlexander HamiltonHamiltonAlexander Hamilton before me Patrick WalshPatrick Walsh a justice of the peace within and for the county of St. LouisSt Louis in the state aforesaid in a certain cause now depending in the Circuit Court of the Country of St. LouisSt Louis aforesaid between Ben a slave plaintiff, and JamesJames woods Defendant on the part of the plaintiff

John Holtz of lawful age
being produced and sworn upon his oath states. That he is
a resident of St.Claire County IllinoisIllinois that
he has their for 18 or 19 years.
That he is acquainted with the by Ben called Ben woods the
plaintiff in this suit that he became acquainte with Ben in IllinoisIllinois>about five years ago. That said Benwas then wroking in the cole mines of
St. Claireclair County, where he remained somewhere
about six or eight weeks at labour
in the mines That he was brought three
witness by a man by the name of Dickensonand was at work in connexion with a man
by the name of -. And furtherthis deponent saith that

and subscribed to before the day and at the place first aforesaid justice

SamuelSamuel Swagart of lawful age being produceed and sworn upon his oath states that he is a citizen of IllinoisIllinois and that about five years ago he was a citizen of St.Louis County IllinoisIllinois That he knows the plaintiff in this suit. That he because, acquainte with him about five years ago, in StSt Claire CountyClaireSt Claire CountyCountySt Claire CountyIllinoisIllinois where he was then working in the Cole mines, that he boarded at deponents House, while working in the mine That said remained then about six in eight weeks,- That he was brought there, from St. LouisSt Louis in MissouriMissouriby a man by the name of grainyerand he was kept in their working the mines until he was brought back to St. LouisSt Louisabout 6 or 8 weeks after he was brought over- Blueford RobinsonRobinsonthe Cole away and witness belives he was in the employ of Dickenson which Cole Ben And further this deponent faith not

sworn and subscribed to before me On the day and at the place first aforesaid Justic

Geroge W. HowardHoward of lawful age being upon his oath states- That, he is a Citizen of IllinoisIllinois St St.ClaireCounty, that he has been residing their about eight years- That he was acquainted with the plaintiff Ben, about five years ago in StSt Claire CountyClaireSt Claire CountyCountySt Claire CountyIllinoisIllinois when he Ben worked then- That he there working in the Cole mixes that he remained there about 8 or nine weeks, that he was brought Their by a man named from St. LouisSt Louis, about the first of november 1833- and remained their at work in the mines until early in January1834- That it was the understanding that he worked there as a servan- That the cole he was By Bluford RobinsonRobinsonand another man to St. LouisSt Louis and be understood from one or both of the haulersthat were hauling for DickensonThat witness heard and the persons hauling speak of Ben as a slave, and say he was a slave- while he was there and fruther this Deponent saith not

his

x

mark sworn and subscribed to before me on the day and at the place first aforesaid

Eliya HowardHoward of lawful age being produceed and sworn upon her oath states that he is a citizen of IllinoisIllinois and that about five years ago he was a citizen of St.Claire County That he knows the plaintiff in this suit. That he because, acquainte with Ben about five years ago, in St County where he was then working in the Cole mines, that he as deponents , which working in te mine That remainded then about six in eight weeks,- That he was brought there, from St. LouisSt Louis in by a man by the name of and he was kept in their working the until he was brought back to St. LouisSt Louis 6 or 8 weeks after he was brought over- the away and belives he was in the employ of which And further this deponent faith not

his

x

mark and subscribed to before me On the day and at the place first aforsaid

Geroge of age being upon his states- That, he is a Citizen of St County, that he has been residing their about eight years- That he was acquainted with the plaintiff Ben, about five years in St County when he Ben worked then- That he there working in the Cole that he remained there about 8 or nine weeks, that he was brought

Their by a man named from St. LouisSt Louis, about the first of november 1833- and remained their at work in the until in 1834- That it was the understanding that he worked there as a servan- That the cole he was By and another man to St. LouisSt Louis and be understood from one or both of the that were for That heard and the persons speak of as a slave, and say he was a slave- while he was there fruther this Deponent saith not

of age being and upon her oath states, That she is a citizen of - that she has then in St County a Ten years That she was with the plaintiff about five years ago this fall- That was then working in the cole in St to That he remainded their about 8 or 9 weeks all the time, That he boarded at the House of Deponent who then lived in House and Deponent cooked for the Ben among the That for the cooking for the hand and for it- That he had another slave Ben there a week, and brought him away and left Ben That the and another man the away which

I, Patrick WalshPatrick Walsh a Justice of the peace within and for the County of St. LouisCounty of St Louis in the state of MissouriMissouri, do hereby Certify that John Geroge and the Deponents were by me severally sworn to testify the whole truth of their knowledge the mater in aforesaid; that they wre examined and their examination reduced to writing and by there respectively subscribed in my presence on the day between the hours and at the place in that behalf first aforesaid

Ben, the plaintiff, was burn a , and at the time repared to, before the commencement of this , was, and state us the property of the defendant, William D. Moods . About five years ago, and before this was , the said woods the said negro to his brother-in-law, and , who was then about to come out for the state of , to lord, who not to this state, and after being look the slave over into St. County, in the state of , for the purpose of working him as a in the coal , and oil work him these as and coal-land for seven or eight works, after which was brought back to this state, and this said was commenced by he slave for his freedom. The in this state, and has done ever came

Some time during the continuance of the employment of the slave in , the said agent, by better, imformed the said then , and in the state of had so employed the said slave in the state of , to & his at the of in his operations at the coal at the time of the was infomed and that would be danger in taking the and get his freedom